ARCHIVED - Public Notice CRTC 2001-110

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Public Notice CRTC 2001-110

Ottawa, 31 October 2001

Conditions of service for wireless competitive local exchange carriers and for 9-1-1 services offered by wireless service providers

Reference: 8669-M16-01/01 and 8669-C12-01/01


The Commission seeks views on terms and conditions for a wireless local exchange carrier offering wireless local telephone service. The Commission also seeks views about issues regarding the provision of 9-1-1 services by mobile cellular service providers.



In Telecom Decision CRTC 97-8, Local competition, dated 1 May 1997, the Commission established a framework for competition in the local exchange markets of the former Stentor member companies. The framework was designed to offer efficient interconnection arrangements and to be technology neutral. The decision noted that should a wireless service provider (WSP) wish to become a competitive local exchange carrier (CLEC), it would be subject to the same terms and conditions as wireline CLECs.


Under the framework of Decision 97-8, Microcell Connexions Inc. filed a General Tariff to operate as a CLEC. On 8 September 2000, the Commission issued Order CRTC 2000-831, General Tariff approved on an interim basis with modifications for Microcell Connexions Inc. The Tariff did not modify the provision of service by Microcell in the exchanges where it operates as a WSP.


Order 2000-831 clarified the regulatory obligations of wireline local exchange carriers (LECs) based on their particular circumstances. It specified a variety of determinations, including some with regard to "equal access" and "9-1-1 related obligations".


With regard to the equal access obligation, paragraph 26 of Order 2000-831 directed Microcell to provide equal-access on mobile originating calls where end-users are roaming within Microcell's CLEC serving areas and on mobile terminating calls, where an end-user is roaming outside the local calling area associated with the home exchange. This requirement is subject to Microcell's ability to provide equal access and the ability of the interexchange service provider (IXSP) to provide the service.


In light of Decision 97-8's obligation that incumbent local exchange carriers (ILECs) interconnect their interexchange networks with every CLEC and the special circumstances introduced by the wireless CLEC's roaming subscribers, Order 2000-831 exempted ILECs from having to interconnect their interexchange networks with Microcell. The exemption, which was contained in paragraph 33, was revised on 2 October 2000:

At this time, the Commission exempts the ILECs from having to interconnect their interexchange networks with Microcell for the purpose of carrying toll calls originated by the end-users of Microcell's resellers in view of the billing and routing issues raised for IXSPs when a wireless CLEC's subscriber roams.


In response to the request contained in paragraph 34 of Order 2000-831, the CRTC Interconnection Steering Committee (CISC) Network Working Group has researched the issues and possible solutions to satisfy "equal access obligations" for roaming subscriber of mobile wireless CLECs.


On 8 December 2000, the CISC Network Working Group submitted its Report on Billing and Routing Alternatives Associated with Roaming End-Customers of Mobile Wireless CLECs. A further report, titled Equal Access For Mobile Terminating Calls, was submitted on 1 May 2001. Both reports have been accepted by the CISC Steering Committee. (Documents NTRE008 and NTRE009, respectively, on the CRTC web site).


The 1 May 2001 consensus report concluded that "based on information provided by Microcell to-date, it appears that Microcell is not in a position to accommodate equal access for mobile terminating calls and call forwarded calls." CISC participants had divergent views about allowing Microcell to operate as a wireless CLEC, the need for further investigation of Microcell's ability to support equal access, and the viability of some technical alternatives.


With regard to "9-1-1 related" obligations, paragraph 51 of Order 2000-831 specified that:

The Commission agrees with the AEAA [Alberta E9-1-1 Advisory Association] that, in an emergency, the information contained in wireless subscribers' records could be of value to the PSAPs [Public Safety Answering Points]. The Commission considers that, as a CLEC, Microcell should provide the end-users of its resellers with 9-1-1 service functionality that is better than what it currently provides them as a WSP. The Commission considers that until Wireless E9-1-1 is implemented, Microcell should support the inclusion of the subscriber records of its resellers' end-users in the ALI [Automatic Location Identifier] databases.


Paragraph 53 added:

The Commission further directs Microcell to implement Wireless E 9-1-1 as soon as the service becomes available in any of the ILECs' serving areas where the company will be operating as a CLEC.


With regard to 9-1-1 service and associated subscriber record obligations, Microcell has recently signed a master agreement for local interconnection (or trunk-side interconnection) to operate as a wireless CLEC in some exchanges in the operating territory of TELUS Communications Inc. (TCI). In the exchanges where Microcell plans to operate as a wireless CLEC, Microcell will implement the Wireless Enhanced 9-1-1 (E9-1-1) functionality to satisfy 9-1-1 related obligations of Order 2000-831 without it being necessary to populate subscriber records in the ALI database.


With regard to populating ALI databases, detailed discussions have taken place in the CISC 9-1-1 Group and captured in their documentation. (Document ESTF029 on the CRTC web site).


In a development that indirectly relates to its 9-1-1 obligations as a wireless CLEC, Microcell filed a Part VII application on 13 March 2000 requesting that the Commission mandate the provision of E9-1-1 network access services by the ILECs who have yet to implement the service.


With this public notice, the Commission seeks comments on appropriate terms and conditions to govern services offered by wireless CLECs, ILEC's associated interconnection obligations and on 9-1-1 services offered by WSPs. Specific issues include those set out below.


Equal access provisions:

a) Should wireless CLECs continue to be subject to the same equal access provisions that are applicable to wireline CLECs?
b) Should equal access obligations of wireless CLECs be suspended due to technical, administrative and/or financial considerations? If so, in what future circumstances, if any, should equal access provisions be re-introduced?
c) Should the equal access obligations of wireless CLECs exist only in regard to outbound toll traffic originated by their mobile subscribers?
d) Should the equal access obligations of wireless CLECs be satisfied by use of the wireless CLEC subscriber's home exchange for purpose of placing and receiving toll calls handled by other long-distance service providers?
e) In light of the increasing prevalence of bundled local/toll-services, as well as the inherent complexities of introducing and sustaining equal access provisions for wireless CLECs, should equal access provisions for wireless CLECs be removed?


9-1-1 service and subscriber records provisions:

a) Should the 9-1-1-related obligations confirmed in Order 2000-831 be maintained?
b) If so, please comment on the difficulties in populating or updating ALI records for mobile subscribers with telephone numbers from an exchange where their provider operates as a wireless CLEC. In particular, comment on scenarios where the wireless CLEC's subscribers:

i) may reside in another exchange of the interconnected LEC (possibly in an another province or the territory served by another PSAP);

ii) may reside in an exchange in the territory of another LEC; or

iii) may change residence without notifying their wireless CLEC provider (in particular for pre-paid service subscribers).

c) Should the obligation confirmed in Order 2000-831 to populate ALI databases with subscriber records be suspended?
d) If this obligation were suspended, should it be suspended in regard to pre-paid subscribers, post-paid subscribers or both?
e) If this obligation were suspended, should it be suspended only for current subscribers, future subscribers or both?
f) If this obligation were suspended in relation to at least some of the wireless CLEC subscribers, should it be retained in relation to subscribers porting telephone numbers from wireline and/or other wireless LECs using local number portability?
g) If this obligation were suspended, should it be replaced by additional obligations for wireless CLECs? For example, additional obligations may include to formally inform (via notices on subscriber's bills, mailing inserts or notices attached to new pre-paid calling cards sold in retail outlets) pre-paid and/or post-paid subscribers of key provisions applicable to 9-1-1 calls, including references to limitations about PSAP call-backs. Notices could also provide the opportunity for subscribers of wireless CLECs who wish to enjoy a higher level of personal safety to request that their subscriber record be included in ALI databases.
h) If the 9-1-1 related obligations of wireless CLECs are maintained, should they be extended to WSPs? In particular, should WSPs be mandated to offer E9-1-1 service to their subscribers in operating territories where E9-1-1 is commercially offered by ILECs?
i) As an alternative to mandating WSPs to offer E9-1-1 services, should the Commission encourage them to offer the E9-1-1 service by limiting their associated legal liability (the Commission has previously foreborne in this regard) or by considering other measures? If so, to what extent should liability be limited and what other measures would be appropriate?



Parties to this proceeding will include all parties registered in the "Microcell Telecommunications Inc. Part VII Application for Mandated Provision of Wireless Enhanced 9-1-1 Network Access Service" proceeding (CRTC file 8669-M16-01/01). We note that these parties include, among others, all ILECs and all WSPs.


Other parties wishing to participate in this proceeding must notify the Commission of their intention to do so, by 15 November 2001. These parties should contactthe Secretary General by mail at CRTC, Ottawa, Ontario, K1A 0N2; by fax at (819) 953-0795; or by email at They are to indicate in the notice their email address, where available. If parties do not have access to the Internet, they are to indicate in their notice whether they wish to receive disk versions of hard copy filings.


The Commission will issue as soon as possible after the registration date, a complete list of interested parties and their mailing address (including email address, if available), identifying those parties who wish to receive disk versions.


Interested parties are invited to file their comments with the Commission concerning, in particular, the issues raised in paragraphs 15 (equal access) and 16 (9-1-1 service and subscriber records) of this proceeding, with supporting rationale, serving copies on all other parties by 20 November 2001.


Interested parties are invited to file reply comments with the Commission about other parties' submissions, serving copies on all other parties by 30 November 2001.


Where a document is to be filed or served by a specific date, the document must be actually received, not merely mailed, by that date.


Parties wishing to file electronic versions of their comments can do so by email at the address shown above, or on diskette.


The electronic version should be in the HTML format. As an alternative, those making submissions may use "Microsoft Word" for text and "Microsoft Excel" for spreadsheets.


Please number each paragraph of your submission. In addition, please enter the line ***End of document*** following the last paragraph. This will help the Commission verify that the document has not been damaged during transmission.


The Commission will make submissions filed in electronic form available on its web site at in the official language and format in which they are submitted. This will make it easier for members of the public to consult the documents.


The Commission also encourages interested parties to monitor the record of this proceeding (and/or the Commission's web site) for additional information that they may find useful when preparing their submissions.


Submissions may be examined or will be made available promptly upon request at the Commission offices during normal business hours:

Central Building
Les Terrasses de la Chaudière
1 Promenade du Portage, Room G-5
Hull, Quebec K1A 0N2
Tel: (819) 997-2429 - TDD: 994-0423
Fax: (819) 994-0218

Bank of Commerce Building
1809 Barrington Street
Suite 1007
Halifax, Nova Scotia B3J 3K8
Tel: (902) 426-7997 - TDD: 426-6997
Fax: (902) 426-2721

405 de Maisonneuve Blvd. East
2nd Floor, Suite B2300
Montréal, Quebec H2L 4J5
Tel: (514) 283-6607 - TDD: 283-8316
Fax: (514) 283-3689

55 St. Clair Avenue East
Suite 624
Toronto, Ontario M4T 1M2
Tel: (416) 952-9096
Fax: (416) 954-6343

Kensington Building
275 Portage Avenue
Suite 1810
Winnipeg, Manitoba R3B 2B3
Tel: (204) 983-6306 - TDD: 983-8274
Fax: (204) 983-6317

Cornwall Professional Building
2125 - 11th Avenue
Room 103
Regina, Saskatchewan S4P 3X3
Tel: (306) 780-3422
Fax: (306) 780-3319

Suite 520 - 10405 Jasper Avenue
Edmonton, Alberta T5J 3N4
Tel: (780) 495-3224
Fax: (780) 495-3214

530-580 Hornby Street
Vancouver, British Columbia V6C 3B6
Tel: (604) 666-2111 - TDD: 666-0778
Fax: (604) 666-8322

Secretary General

This document is available in alternative format upon request and may also be examined at the following Internet site:

Date Modified: 2001-10-31

Date modified: